Is it OK to re-disclose a corrected APR after loan-closing?
04/23/2023
In post-closing review, we noticed a loan’s APR is understated outside of tolerance. Can we just send a new disclosure showing the correct APR to fix this inadvertent error?
Rebekah is a sought-after compliance expert, the VP Director of Compliance for $6 billion community bank in Montana, and the owner of Elucidate LLC.
Elucidate means to "make clear, explain, throw light upon", and describes Rebekah's desire to illuminate the complexities of compliance with passion and fun. She's created and produced a TRID music video parody and several Compliance Breakout escape rooms, which she frequently provides at state banking compliance conferences. She is an accomplished speaker and regularly provides webinars through Compliance Resource, LLC.
Rebekah is currently serving as the VP Director of Compliance for a $6 Billion community bank in Montana. She began her career in 1995 at a private lending company, but soon settled into banking, where she's covered nearly all of it - customer service and teller work, loan processing and review, and security and business continuity. She now oversees CRA, BSA and all aspects of compliance as a senior leader. She has successfully navigated numerous FDIC Compliance, CRA, and BSA Exams.
Rebekah has a bachelor's degree in Organizational Leadership from Chapman University (Magna cum Laude), attended the American Bankers Association National Compliance School in 2003, and has held her Certified Regulatory Compliance Manager designation since 2006.
04/23/2023
In post-closing review, we noticed a loan’s APR is understated outside of tolerance. Can we just send a new disclosure showing the correct APR to fix this inadvertent error?
04/16/2023
An auditor just told us we have an APR violation (but not a TRID violation) on a consumer real estate loan, that that we need to make restitution to the borrower. Don’t we need to send a corrected Closing Disclosure too?
04/09/2023
We messed up an APR beyond Reg Z tolerance, and know we need to give the borrower restitution. But how do we figure out the right amount to give?!
04/02/2023
Our marketing department believes “Member FDIC” mucks up our bank’s social media posts, and says we don’t need it anyway, so long as it is “one-click-away” through a link to our website. They want to get rid of it. I’m not so sure. Are they right?
03/26/2023
If the money is not available in the deceased customer’s account and no estate account exists with the bank, is the bank still liable for reclamations from Treasury?
03/26/2023
Must a lender’s NMLS ID # be included in advertisements?
03/19/2023
Being in Compliance, I feel like I’m always at odds with the Marketing department. How can I get them to understand how important the rules are?
03/12/2023
I’ve heard rumors of a new FDIC digital sign requirement for “Member FDIC”. What is that all about?
03/05/2023
What are some of the biggest landmines in lending advertisements?
02/26/2023
Help! We just found out a creative loan officer has started their own You Tube channel and is posting videos to promote her real-estate lending expertise at our bank. She’s also giving shout-outs to realtor friends! What do we do?